Privacy Policy — How p646 Handles Your Data

p646 acts as the personal information controller in respect of the personal data of registered users collected through the p646 Platform at p646.club. As a personal information controller under the Philippine Data Privacy Act, p646 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

p646 operates within PAGCOR-regulated frameworks applicable to online gaming platforms serving users in the Republic of the Philippines. These regulatory obligations necessarily require the collection and retention of certain personal data relating to registered users, including identity verification records, financial transaction histories, and gaming activity logs.

Where p646 engages third parties to process personal data on its behalf — including payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank, as well as KYC verification providers — those third parties act as personal information processors and are contractually required to handle your data only in accordance with p646's instructions and applicable law.

p646 collects the following categories of personal data from registered users and visitors to the Platform:

p646 collects personal data through the following channels and methods:

• Direct submission at registration: When you create a p646 account, you provide your name, date of birth, contact details, and other identity information directly through the registration form.
• Payment transactions: When you make a deposit or submit a withdrawal request via GCash, PayMaya, BPI, BDO, or Metrobank, our payment processors transmit relevant financial identifiers to your p646 account record.
• KYC document submission: When you upload identity verification documents in response to a p646 verification request, those documents are processed and stored by our KYC provider and cross-referenced with your p646 account.
• Automated technical collection: As you browse and use the Platform, we automatically collect technical data including your IP address, device type, browser information, pages viewed, session timestamps, and interaction patterns through server logs and analytics tools.
• Cookies and similar technologies: p646 uses cookies and similar tracking mechanisms as described in Section 8 of this Policy.
• Support interactions: When you contact the p646 support team via live chat or email, we record and retain the content of those communications for quality assurance and dispute resolution purposes.

p646 uses your personal data for the following purposes:

4.1 Account Administration and Platform Operation

Processing your registration, maintaining your account, authenticating your identity at login, managing your p646 wallet balance, crediting deposits, and processing withdrawal requests. This use is necessary to fulfil the contract between you and p646.

4.2 Regulatory Compliance

Verifying that you meet the minimum age requirement of 21 years before granting access to gaming features. Conducting KYC and anti-money laundering (AML) checks as required by PAGCOR-regulated operational frameworks and applicable Philippine law. Responding to requests from PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other lawful authorities.

4.3 Responsible Gaming

Monitoring gaming activity patterns to identify potential signs of problem gambling behavior. Enforcing responsible gaming settings you have applied to your account, including deposit limits, loss limits, session time restrictions, and self-exclusion periods.

4.4 Security and Fraud Prevention

Detecting and investigating suspicious account activity, fraudulent transactions, duplicate account registrations, and violations of the p646 Terms & Conditions. Technical data and gaming activity records are used to identify abnormal patterns indicative of automated betting tools or collusion.

4.5 Customer Support

Responding to your support inquiries, resolving disputes regarding transaction records or game outcomes, and maintaining records of communications for quality assurance.

4.6 Service Improvement and Analytics

Analyzing aggregated and anonymized usage data to improve Platform performance, game availability, payment processing reliability, and the overall experience for Filipino players. Individual user data is not disclosed in this context.

Under the Philippine Data Privacy Act, p646 processes your personal data on the following legal bases:

1. Contractual necessity: Processing required to enter into and perform the contract with you — including operating your account, processing deposits and withdrawals, and granting access to gaming features.
2. Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulatory requirements, AML obligations under Republic Act No. 9160 as amended, and data retention mandates.
3. Legitimate interests: Processing necessary for fraud prevention, security monitoring, responsible gaming enforcement, and Platform improvement activities, where such interests are not overridden by your privacy rights.
4. Consent: Processing for marketing communications and non-essential analytics, where you have provided specific, informed, freely given, and unambiguous consent. You may withdraw consent for such processing at any time through your account settings.

p646 does not sell, rent, or trade your personal data to third parties for commercial purposes. Your data is shared only in the following limited circumstances:

6.1 Payment Processors

To process your GCash, PayMaya, BPI, BDO, and Metrobank transactions, p646 shares necessary financial identifiers with the relevant payment service providers. These processors are bound by their own applicable data protection obligations and are authorized to use your data only to complete the transaction.

6.2 KYC and AML Verification Providers

Identity documents and related data are shared with licensed KYC verification service providers engaged by p646 to perform identity verification and AML screening. These providers act as personal information processors under written agreements with p646.

6.3 Regulatory Authorities

p646 is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council, the National Privacy Commission, law enforcement agencies, and courts of competent jurisdiction in the Philippines when required by applicable law, valid legal process, or regulatory mandate.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of p646's assets, your personal data may be transferred to the acquiring entity, which will be bound by obligations at least as protective as those set out in this Policy.

p646 retains your personal data for as long as necessary to fulfil the purposes described in this Policy, including compliance with legal and regulatory retention obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account relationship with p646 and for a minimum of five (5) years following account closure, in accordance with PAGCOR-regulated record-keeping requirements and AML obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by applicable Philippine financial regulations.
• Gaming activity logs: Retained for a minimum of two (2) years from the date of each session or event.
• Communications records: Retained for two (2) years from the date of the communication, or longer where relevant to an unresolved dispute.
• Technical and usage data: Retained in identifiable form for up to twelve (12) months, after which it may be retained in anonymized or aggregated form for analytical purposes.

When personal data is no longer required for any legitimate purpose, p646 will securely delete or anonymize it.

p646 uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device when you access the Platform. They are used for the following purposes:

• Essential cookies: Necessary for the Platform to function correctly. These include session authentication cookies that keep you logged in to your p646 account during a session, and security cookies that help detect suspicious activity. Essential cookies cannot be disabled without preventing the Platform from functioning.
• Functional cookies: Retain your preferences such as language settings, game lobby display preferences, and responsible gaming settings between sessions.
• Analytics cookies: Collect aggregated information about how users navigate the Platform, which pages are most visited, and which features are most frequently used. This data helps p646 improve the Platform experience. Analytics cookies are non-essential and can be disabled.

Your browser settings allow you to control and delete cookies. Note that disabling essential cookies will prevent you from logging in to or using your p646 account. p646 does not use third-party advertising cookies or behavioral tracking cookies for external advertising purposes.

Under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by p646:

1. Right to be informed: The right to know that your personal data is being collected, the purposes for collection, and how it will be used — as provided in this Policy.
2. Right of access: The right to request a copy of the personal data p646 holds about you. Access requests may be submitted to [email protected]. p646 will respond within 15 business days of receipt.
3. Right to rectification: The right to have inaccurate or incomplete personal data corrected. You may update most account information directly from your p646 account settings. For corrections to identity documents or financial records, contact support.
4. Right to erasure: The right to request deletion of your personal data where it is no longer necessary for any legitimate purpose and no legal obligation requires its continued retention. Certain data cannot be deleted while retention obligations under PAGCOR-regulated frameworks or Philippine law remain in effect.
5. Right to object: The right to object to the processing of your personal data where processing is based on p646's legitimate interests, or where processing is for direct marketing communications.
6. Right to data portability: The right to receive a machine-readable copy of personal data you have provided to p646 for use with another controller, where technically feasible.
7. Right to lodge a complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your personal data has been processed in violation of your rights under the Data Privacy Act.

The p646 Platform is strictly intended for individuals who are at least 21 years of age, consistent with PAGCOR regulations governing casino-style gaming in the Philippines. p646 does not knowingly collect personal data from any individual under the age of 21.

Age verification is conducted as part of the registration and KYC process. Where p646 discovers or reasonably suspects that personal data relating to an individual under 21 years of age has been collected, p646 will immediately suspend the relevant account, initiate an investigation, return any deposited real-money funds to the verified payment source, and delete the personal data of the underage individual to the extent permitted by law.

p646 implements a range of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS 1.3) encryption for all data transmitted between your device and the p646 Platform.
• Encryption of sensitive personal data at rest within p646 infrastructure using AES-256 or equivalent standards.
• Role-based access controls restricting internal access to personal data to authorized personnel only, on a need-to-know basis.
• Regular security assessments and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for p646 staff accessing systems that process personal data.
• Monitoring systems that detect and alert on anomalous access patterns or data exfiltration attempts.

While p646 takes all reasonable steps to protect your personal data, no electronic transmission or storage system is unconditionally secure. You are encouraged to use a strong, unique password for your p646 account and to log out of your session on shared devices.

p646 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, PAGCOR-regulated compliance requirements, or our data processing practices. The revised Policy will be published at p646.club/privacy-policy with an updated effective date.

Where amendments are material — meaning they significantly affect your rights or our use of your data — p646 will make reasonable efforts to notify registered users via email or an in-platform notification prior to the effective date of the change. Your continued use of the Platform following the effective date of any amendments constitutes acceptance of the updated Policy.

If you have questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a privacy concern, you may contact p646 as follows: